ML24312A166
| ML24312A166 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/07/2024 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Reynolds R Constellation Energy Generation |
| References | |
| EPID L-2024-LLA-0080 | |
| Download: ML24312A166 (1) | |
Text
From:
Richard Guzman To:
Reynolds, Ronnie J:(Constellation Nuclear)
Cc:
Hipo Gonzalez
Subject:
Nine Mile Point Unit 1 - REQUEST FOR ADDITIONAL INFORMATION - LAR to Revise TSs to Adopt TSTF-230, Revision 1, "Add New Condition B to LCO 3.6.2.3" (EPID L-2024-LLA-0080)
Date:
Thursday, November 7, 2024 7:59:02 AM
- Ron, On October 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff sent Constellation Energy Generation, LLC (CEG, the licensee) the subject Request for Additional Information (RAI) as a draft e-mail. This RAI supports the staffs review of the licensees June 13, 2024 (ML24165A223), license amendment request (LAR) for Nine Mile Point Nuclear Station, Unit No. 1 (NMP1).The licensee proposes adoption of Technical Specification Task Force (TSTF)-230, Revision 1, Add New Condition B to LCO [Limiting Condition for Operation] 3.6.2.3, RHR Suppression Pool Cooling. The TSTF modifies improved TS (ITS) 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling, to allow two RHR suppression pool cooling subsystems to be inoperable for eight hours.
NMP1 does not have ITSs; therefore, the applicable LCO for NMP1 is TS LCO 3.3.7, Containment Spray System. Additionally, a new Specification is proposed to be added that will direct operators to place the unit in Shutdown Condition - Hot within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Shutdown Condition - Cold in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if applicable specifications are not met.
The NRC staff and CEG held a conference call on November 5, 2024, to discuss clarifications on the draft RAI.Updated below is the official (final) RAI.As discussed on the call, please provide a response to this question within 30 days of this e-mail communication or no later than December 9, 2024. This email communication will be placed in ADAMS as an official agency record. Please contact me if you have any questions concerning this request.
Thank you, Richard V. Guzman Sr. Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Phone: 301-415-1030 Richard.Guzman@nrc.gov
DOCKET NO. 50-220 (EPID: L-2024-LLA-0080 INTRODUCTION By letter dated June 13, 2024 (ADAMS Accession No. ML24165A223), Constellation Energy Generation, LLC (CEG, the licensee) submitted a license amendment request (LAR) for Nine Mile Point Nuclear Station, Unit No. 1 (NMP1). The licensee proposes adoption of Technical Specification Task Force (TSTF)-230, Revision 1, Add New Condition B to LCO [Limiting Condition for Operation] 3.6.2.3, RHR Suppression Pool Cooling. The TSTF modifies improved TS (ITS) 3.6.2.3, Residual Heat Removal (RHR)
Suppression Pool Cooling, to allow two RHR suppression pool cooling subsystems to be inoperable for eight hours. NMP1 does not have ITSs; therefore, the applicable LCO for NMP1 is TS LCO 3.3.7, Containment Spray System. Additionally, a new Specification is proposed to be added that will direct operators to place the unit in Shutdown Condition -
Hot within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Shutdown Condition - Cold in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if applicable specifications are not met. During its review of the LAR, the NRC staff identified the need for additional information.
REGULATORY BASIS The regulation at 10 CFR 50.36(c)(2) requires that TSs include LCOs. Per 10 CFR 50.36(c)
(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. This regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.
The regulation at Title 10 to the Code of Federal Regulations (10 CFR) Section 50.36(c)(2) requires that TSs include limiting conditions for operation (LCOs). Per 10 CFR 50.36(c)(2)
(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132, dated July 22, 1993) explained that the new STS should also provide improvements to the Bases Section of the specifications, which provides the purpose for each requirement in the specification.
REQUEST FOR ADDITIONAL INFORMATION The proposed change to NMP1 CSS LCO 3.3.7 in part states, If both containment spray systems become inoperable, or if one containment spray system and one subsystem in the opposite loop become inoperable, the reactor may remain in operation (emphasis added). The proposed change adds new terminology to the CSS LCO 3.7.7 description, for example, subsystem and opposite loop. Similar changes (mark-ups) were provided for the associated NMP1 Bases.
REQUEST FOR ADDITIONAL INFORMATION ADOPTION OF TSTF-230, REVISION 1, ADD NEW CONDITION B TO LCO 3.6.2.3 RESIDUAL HEAT REMOVAL SUPPRESSION POOL COOLING CONSTELLATION ENERGY GENERATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT 1
As described in the Commissions policy statement on technical specification improvements, the Bases Section of the specifications clarifies each requirement in the specification. Given that NMP1 uses the CSS for suppression pool cooling and does not have standard specifications, the NRC staff expected the NMP1 Bases for LCO 3.3.7 to explain the proposed new LCO requirements (e.g., what constitutes a CSS subsystem orCSS opposite loop). However, the NMP1 Bases mark-ups did not provide clarifying information. Therefore, the NRC staff requests that the licensee provide information in the NMP1 Bases that clarifies the terminology used in the proposed change to NMP1 CSS LCO 3.3.7.
From: Richard Guzman Sent: Thursday, October 31, 2024 7:25 PM To: Reynolds, Ronnie J:(Constellation Nuclear) Ronnie.Reynolds@constellation.com
Subject:
Nine Mile Point Unit 1 - DRAFT Request for Additional Information, LAR to Revise TSs to Adopt TSTF-230, Revision 1, "Add New Condition B to LCO 3.6.2.3" (EPID L-2024-LLA-0080)
- Ron, By letter dated June 13, 2024 (ADAMS Accession No. ML24165A223), Constellation Energy Generation, LLC (CEG, the licensee) submitted a license amendment request (LAR) for Nine Mile Point Nuclear Station, Unit No. 1 (NMP1).The licensee proposes adoption of Technical Specification Task Force (TSTF)-230, Revision 1, Add New Condition B to LCO [Limiting Condition for Operation] 3.6.2.3, RHR Suppression Pool Cooling. The TSTF modifies improved TS (ITS) 3.6.2.3, Residual Heat Removal (RHR)
Suppression Pool Cooling, to allow two RHR suppression pool cooling subsystems to be inoperable for eight hours. NMP1 does not have ITSs; therefore, the applicable LCO for NMP1 is TS LCO 3.3.7, Containment Spray System. Additionally, a new Specification is proposed to be added that will direct operators to place the unit in Shutdown Condition -
Hot within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Shutdown Condition - Cold in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if applicable specifications are not met.
The NRC staff has determined that additional information is needed to complete its review, as described in the request for additional information (RAI) shown below. This RAI is identified as DRAFT at this time to confirm your understanding of the information needed by the NRC staff to complete its evaluation. Please let me know your groups availability for a clarification call if desired, and I will coordinate availabilities w/the NRC technical staff.I would like to hold the call within the next two weeks, if needed, as I plan to issue the questions as an official RAI no later than November 14th.
- Thanks, Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-10H17 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov